Presentation on theme: "LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Disused Sources Working Group Implementation Phase Organization of Agreement States Annual Meeting Chicago, ILAugust."— Presentation transcript:
LOW-LEVEL RADIOACTIVE WASTE FORUM, INC. Disused Sources Working Group Implementation Phase Organization of Agreement States Annual Meeting Chicago, ILAugust 24-28, 2014 Ray Fleming, Disused Sources Working Group Chair
Working Group Members 2 Kathy Davis – Southwestern Compact Leo Drozdoff – Nevada Department of Conservation and Natural Resources Ray Fleming – Texas Department of State Health Services (Chair) Mike Garner – Northwest Compact Leigh Ing – Texas Compact Rich Janati – Pennsylvania Department of Environmental Protection Susan Jenkins – South Carolina Department of Health and Environmental Control Rusty Lundberg – Division of Radiation Control, Utah Department of Environmental Quality Mike Mobley – Southeast Compact Leonard Slosky – Rocky Mountain Compact
Source Disposal is Important 3 No matter how you reach that conclusion sources eventually need to be buried.
Lack of Planning 4 Many Licensees do not plan for disposal or do not dispose of sources in a timely manner Excuses - “planned” reuse, disposal too costly, shipping problems, procrastination
Life Cycle Cost Education 5 Ask questions when licensing or inspecting. What Waste do they have? Who receives their waste? How much does disposal cost? What is the funding source? When will it happen? What happens with the last sources that they cannot exchange 1-for-1?
Life Cycle Cost Outreach 6 An organized outreach program by: NRC, NNSA and States CRCPD or HPS Topics Why is disposal necessary Costs of disposal – Some realistic numbers would be great Disposal Choices - Manufacturers, Brokers, OSRP, SCATR Encourage Disposal
OSRP and SCATR 7 Continue to support both programs Find ways to make them even more successful in your state.
Add New Disposal Funding Options 8 Manufacturer/Waste Broker Pre-Payment Plans State Pre-Payment Plans State Disposal Funds State Orphaned Source Recovery Programs Other Ideas?
Reassess Financial Assurance 9 $113,000 will not cover every licensee with sealed sources above financial assurance activity limits. (10 CFR §30.35(d)) $113,000 may not even cover licensees who do not need financial assurance by rule. (ex. 100,000 Curies Cs-137) Financial assurance must accurately reflect disposal costs.
Fees to Encourage Disposal 10 Licensing Fees Per Source Storage Fees Other Ideas?
Storage Time Limits 11 Make a 2-year disposal time limit the rule. Make it 1 year for manufacturers, distributors, service companies and brokers. Enforce the two year limit for GLs. Require formal plans of reuse or recycling for those who seek to avoid the time limits.
Support Reuse and Recycling 12 Allow individual licensees to reuse and recycle when they have an approved plan. Promote the exchange of usable sources intended for reuse and recycle. Promote an active Source Exchange Program when one becomes available.
States with Waste Disposal Sites 13 Implement the revised concentration averaging BTP when it becomes official. Consider new higher limits under site specific criteria.
What we ask is: 14 Please read the disused source working group recommendations with an open mind. Support the ones you agree with. Coordinate with the DSWG on those recommendations. Take actions at the state level to implement those within your control. Download the report at http://www.llwforum.org